The appointment of Tonio Borg as the new commissioner for health and consumer protection is an extremely demanding role, in part because of the consideration he now has to give to the tobacco products directive drafted by his predecessor, John Dalli.

Some of the provisions in Dalli’s draft were extreme and less than rational. Already, cigarette smuggling and counterfeiting cost the EU €10 billion in tax revenues every year. Dalli’s proposals would increase tobacco smuggling, remove billions of euros from the coffers of EU member states and result in massive job losses in the tobacco retailing industry. The livelihoods of one and a half million people who sell tobacco would be at risk. That prospect prompted thousands of retailers to take part in protests across Europe in September.

The proposals would also be ineffective. The standardisation of packages, covering them with shocking images, would make brands unrecognisable.

A ban on displays of tobacco products at the point of sale would encourage people to turn to people who can display their products – namely, to those who smuggle, or counterfeit, cigarettes from countries where such display bans do not apply. The effect would be to increase the attractiveness of products not subject to EU health and quality checks.

The notion that these measures will improve public health does not rely on scientific evidence.

Education and prevention campaigns have, by contrast, been proven to be effective in reducing tobacco consumption. The EU should therefore focus on prevention.

Instead, the EU has chosen to target retailers and their families. Retailers currently operate within a highly regulated environment. They sell a special product in keeping with rules and common sense, selling exclusively to adults who are aware of their choices. Selling tobacco through retailers limits the volume of sales through illegal networks.

Retailers’ concerns and views should be listened to. We would like to suggest that Commissioner Borg re-open the dialogue with retailers’ associations.

As they stand, Dalli’s proposals would help smugglers, harm retailers and do no proven good for the public.